|
The US, the first country to adopt a comprehensive Transfer Pricing legislation |
|
|
1979 |
OECD report on “Transfer Pricing and Multinational Enterprises” |
|
1984 |
OECD report on “Transfer Pricing and Multinational Enterprises - Three Taxation Issues” |
|
1987 |
OECD report on “Thin Capitalization” |
|
1994 |
US releases its final Transfer Pricing regulations under section 482 of the Internal Revenue Code |
|
1995 |
OECD releases TP Guidelines (Rework of 1979 Report) |
|
2013 |
OECD launches BEPS Action Plan |
|
2015 |
OECD releases solutions to BEPS |
|
2016 |
OECD releases standardized electronic format for the exchange of BEPS Country-by-Country Reports |
|
2017 |
OECD releases updates to TP Guidelines |
|
2018 |
The UAE joins the Inclusive Framework on BEPS |
|
2019 |
The international community agrees on a road map for resolving the tax challenges arising from digitalization of the economy |
|
2022 |
OECD’s latest update to Transfer Pricing Guideline |
The OECD Guidelines are regarded as the most important document in drafting Transfer Pricing legislation as well as in interpreting the provisions.
Since 2017, OECD has released Transfer Pricing guidance notes on application of PSM, various typical transactions, like Financial Transactions, Hard to Value Intangibles, etc., which have been incorporated in OECD’s latest updated TP Guidelines released in January 2022
Transfer Pricing Country
Profiles issued by the OECD
|
Albania |
Finland |
Liechtenstein |
Senegal |
Egypt |
|
Angola |
France |
Lithuania |
Seychelles |
Saudi
Arabia |
|
Argentina |
Georgia |
Luxembourg |
Singapore |
Latvia |
|
Australia |
Germany |
Maldives |
Slovak Republic |
Russian Federation |
|
Austria |
Greece |
Malaysia |
Slovenia |
Liberia |
|
Belgium |
Honduras |
Malta |
South
Africa |
Korea |
|
Brazil |
Hungary |
Mexico |
Spain |
Romania |
|
Bulgaria |
Iceland |
Netherlands |
Sri
Lanka |
Estonia |
|
Canada |
India |
New Zealand |
Sweden |
Uruguay |
|
Chile |
Indonesia |
Nigeria |
Switzerland |
|
|
China [People’s Republic of China] |
Ireland |
Norway |
Tunisia |
|
|
Colombia |
Israel |
Panama |
Turkiye |
|
|
Costa Rica |
Italy |
Papua New Guinea |
Ukraine |
|
|
Croatia |
Jamaica |
Peru |
United Kingdom |
|
|
Czech Republic |
Japan |
Poland |
United States |
|
Transfer Pricing Rules and Regulations around the world continue to grow in number and complexity. Around 125 Countries have adopted BEPS – Action 13 requirements i.e.Transfer Pricing methods, benchmarking requirements, penalties for non-compliance, assessments, and opportunities for Advance Pricing Agreements.
Though some countries have been more successful than others in administering Transfer Pricing legislation, which depends mainly on the human and material resources available with the tax administrations, capitalized experience, the characteristics of the regulations, the political will to address the issues, and their ability to address tax planning, among other aspects. Most of them have accepted the fact that some action is required.
The latest in the race is Cyprus, which has passed a law to introduce Transfer Pricing rules and documentation requirements in accordance with recommendations of the OECD TP Guidelines.
